2026 EPR Compliance: Why preparation today is non-negotiable

Introduction

Whilst transition to Extended Producer Responsibility (EPR) for packaging (pEPR) dominated much of 2025, producers who assume the hard work is now done are risking costly surprises. So, now is not the time to rest on one’s laurels.

In fact, the new year will bring a fresh wave of wider EPR compliance challenges and opportunities directly affecting companies’ regulatory and operational requirements. Here are three of the most significant:

1. Eco-modulated fees arrive: The most notable change will be the introduction of eco-modulated packaging fees, with the first invoices expected in the second half of 2026. Compliance costs will now be determined by the recyclability of packaging under the Recyclability Assessment Methodology (RAM). Packaging classified as ‘Green’ will benefit from reduced fees, funded by the additional charges levied on problematic packaging. This means ‘Red’-rated materials (any packaging not assessed under RAM) will face escalating penalties, starting out as 1.2x the base fee in 2026/27, rising to 2.0x the base fee in 2028/29. Meanwhile, sustainable alternatives could reduce costs by up to 50%.
2. Nation of Sale reporting: Nation of Sale reporting (whether a product is sold in England, Scotland, Wales or Northern Ireland) is a delayed part of EPR for packaging data reporting. However, although the deadline for reporting falls in April 2027 – it applies to sales destination for 2026 – so setting up and maintaining accurate data collection for this now is important.
3. New WEEE requirements: Beyond packaging, 2026 introduces fresh regulatory responsibilities. For example, vape producers must fund collection and recycling costs to meet new targets. Online Marketplaces (OMPs) are now classified as producers for non-UK sellers on their platforms, and they must register for WEEE compliance.

For further information on each of these, why not read our full rundown .

Act now

Packaging producers should conduct a full packaging audit now, assess all materials under RAM to avoid defaulting to Red classification, and strengthen data collection systems for Nation of Sale reporting requirements to ensure they meet UK Extended Producer Responsibility compliance requirements.

As with all things EPR, planning is key to minimising the burden. Contact ERP UK for expert guidance and EPR compliance support, helping you navigate 2026’s intensifying producer responsibility regulations in the UK, turn regulatory obligations into competitive advantage, and protect your business from avoidable costs.

Fraud alert: Fake Packaging EPR (pEPR) invoices targeting UK producers

Recently, PackUK, the administrator for the UK’s packaging Extended Producer Responsibility (pEPR) scheme, issued an urgent fraud warning after counterfeit payment demands began circulating to producers across the country. Here’s what you need to know:

The scam

Businesses are receiving sophisticated emails designed to mimic official Notices of Liability (NoLs) for their packaging obligations. These fraudulent messages may direct recipients to fake government websites or payment portals, which attempt to divert genuine compliance payments into the hands of criminals.

The scam is particularly dangerous because it exploits the complexity of the pEPR regulations and the fact that many businesses are still navigating their obligations for the first time. Fraudsters are taking advantage of this uncertainty to create convincing correspondence that appears legitimate.

The financial risk is clear, but the compliance implications are equally serious. A producer who pays a fraudulent invoice believing they have settled their legal obligations will still be liable for non-compliance penalties – in addition to the money lost to the scam.

With penalty rates of the greater of up to 20% of unpaid fees or 5% of UK turnover (2% for individuals), the consequences of falling victim to this fraud extend far beyond the initial loss.

How to protect your business

PackUK is urging all producers to exercise extreme caution when receiving any correspondence about pEPR obligations. Before taking any action:

• Verify the source: Carefully check the sender’s email address for inconsistencies or unusual domains.
• Do not click links: Fraudulent emails may contain links to convincing but fake portals designed to harvest payment details.
• Use official channels: Log in directly to the Government’s ‘Manage your packaging data’ portal to check your liability status and make payments securely. Or, go straight to PackUK’s official Report Packaging Data (RPD) accounts.

PackUK added that it will never send producers a payment link via email and warned that scammers may also attempt to make contact via telephone or letter.

Report suspicious activity

Any suspected fraudulent correspondence should be reported immediately to help authorities track and combat this criminal activity. Producers who are uncertain about the legitimacy of any communication regarding their EPR obligations should contact their compliance scheme directly for verification. You can contact the EPR support desk by emailing eprcustomerservice@defra.gov.uk.

Vigilance is the first line of defence. Taking a few precious moments to verify correspondence could save your business from both significant financial loss and compliance penalties.

Act before the pressure builds

2026 will test whether packaging producers are truly EPR-ready. Eco-modulated fees, expanded reporting requirements and wider producer obligations mean the cost of inaction is rising fast.

Don’t wait for invoices, penalties or operational disruption to expose gaps in your compliance strategy. Now is the time to audit your packaging, strengthen data systems and build the processes that will protect your business and unlock long-term value.

Ready to take control of your EPR obligations?

Contact ERP UK for expert, confidential guidance on navigating the next phase of packaging and wider EPR. Our team combines regulatory insight with practical recycling compliance solutions to help you stay compliant, avoid unnecessary costs and turn regulation into competitive advantage.

Contact ERP UK today and speak to our EPR specialists to start preparing with confidence.

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